Commonwealth v. Carroll
412 Pa. 525, 194 A.2d 911 (1963)
- Carroll and his wife were having marital problems. One night, in bed, the two had a huge argument. According to Carroll, he saw his handgun lying next to the bed, and without thinking picked it up and shot her in the head.
- Carroll testified that at the time he was in a rage and/or a panic.
- Carroll was arrested and charged with murder.
- The Trial Court convicted Carroll of first-degree murder and sentenced him to life in prison. He appealed.
- According to Pennsylvania law, first-degree murder included “killing by poison, lying in wait, or any other kind of willful, deliberate, and premeditated murder.”
- Carroll argued that his act was not premeditated because he didn’t plan to shoot her. He just saw the gun and did it.
- Killing without premeditation is only second-degree murder, which carries a lesser penalty.
- The Pennsylvania Supreme Court upheld the conviction.
- The Pennsylvania Supreme Court found that Carroll did have premeditate, even if only for a few seconds. That’s long enough to sustain a first-degree murder conviction.
- “No time is too short for a wicked man to frame in his mind the scheme of murder.”
- The case basically says that as long as you act with a deliberate intent to kill someone, that can count as premeditation, even you don’t plan the murder and think about it for a while.
- In the similar case of Young v. State (428 So.2d 155 (1982)) it was said that, “premeditation and deliberation may be formed while the killer is pressing the trigger that fired the fatal shot.”
- Under the standard given in this case, there doesn’t seem to be any distinction between first-degree murder and second-degree murder.
- Compare to State v. Guthrie (461 S.E.2d 163 (1995)), which said that there must have been an opportunity for some reflection on the intention to kill after it is formed in order to sustain a first-degree murder charge.